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HomeMy WebLinkAboutCUP 194A; Aquaculture Systems International; Conditional Use Permit (CUP) (14)1 July 5, 1990 TO : CITY MANAGER ASSISTANT CITY MANAGER CITY ATTORNEY COMMUNITY DEVELOPMENT DIRECTOR UTI LITIES/MAINTENANCE DIRECTOR GENERAL MANAGER, CMWD FROM: City Engineer AGUA HEDIONDA LAGOON - PROPOSED COLIFORM STUDY Attached is my response to the Water Quality Control Board's letter of June 11, 1990. Please review and give me your commentsIsuggested revision by July 10, for submittal to the Board on July 11. LLOYPYB. HUBBS City Engineer LBH/pmj Att. " / DRAFT r - 1 July 5, 1990 Mr. Arthur L. Coe Acting Executive Officer State of California San Diego Regional Water Quality Control Board 9771 Clairemont Mesa Blvd., Suite B San Diego, CA 92124 AGUA HEDIONDA LAGOON - PROPOSED COLIFORM SrUDY Dear Mr. Coe: The City is in receipt of your June 11, 1990 letter concemhg the Regional Board's proposed action on the Agua Hedionda Lagoon Coliform Study. y LJC I'C was surprised to learn that the Board is now considering naming the City of Carlsbad as a responsible party to participate in this study. This action would appear to be an after- thought, in that we are excluded from the proposed study Technical Review Committee. it is also apparent that the study design is primarily oriented towards impacts of the sewer outfalls. The impacts of non-point source pollution is a complex and difficult issue that is only now being fully explored. The EPA and the State Water Quality Control Board are just beginning to develop the data required to formulate and implement effective control strategies. It will likely be years before cost-effective solutions to this problem will be identified and funding sources developed to insure effective control. The City of Carlsbad, because of its interest in preserving its lagoons, hopes to take a leadership role in assisting to develop solutions within the framework of the proposed Order No. 9042 NPDES pennit being reviewed-;- , From the perspective of Encina Water Pollution Control Facility (WPCF) and Oceanside, we concur in the position that the impact of ocean outfalls on shell fishing operations is an important issue that should be dealt with aggressively at the State level. It is neither Cd 1 I w4~ 3 ks s to bear the burden issues G4 proposed study ies of limited 2075 Las Palmas Drive Carlsbad, California 92009-4859 (619) 438-1 161 I, f f' 1"- J Arthur L. Coe Agua Hedionda Lagoon July 5, 1990 Page: 2 Prior to proceeding further with the proposed study, it would be our suggestion that methods be explored to eliminate the immediate health hazards to the Seafarms West Aquaculture operation and proceed with a more global coastal study to resolve the safest means of protecting the ocean environment on a statewide and national basis. The City of Carlsbad is currently reviewing an extension request for the Seafarms West Conditional Use Permit and will be very concerned to insure that the facility can be operated safely before such an extension would be granted. The issue of non-point source pollution will be resolved under EPA guidelines and the Regional Board's program, as outlined in Order 90-42. This approach is the most - " I ., I reasonable, fair and effective one in dealing with issues far broader than the Agua -* -J' - .- Hedionda Lagoon. -' J Should the Board proceed to order the proposed Agua Hedionda Lagoon Study, it should either exclude the City of Carlsbad or expand the non-point source evaluation to include all contributing agencies. Any non-point source evaluation should include all sources within the study zone. This would include all agencies whose runoff is tributary to the Buena Vista Lagoon, Encinas Creek, Batiquitos Lagoon and other non-point source contributors to the Agua Hedionda Lagoon. This would involve most North County agencies which are already otherwise represented by either Oceanside or the Encina WPCF. There would seem to be little reason to single out Carlsbad or the Agua Hedionda Lagoon to deal with a more global issue. I would request that this letter be entered into the record of the July 16 hearing, and that the City of Carlsbad be given an opportunity to give testimony at the hearing. Thank you for your consideration. Cordially, LLOYD B. HUBBS City Engineer LBH:rz c: City Manager Assistant City Manager City Attorney Community Development Director Utilities and Maintenance Director Assistant City Engineer R. J. Greaney - Carlsbad Municipal Water District R. W. Graff - Encina Water Pollution Control Facility a SUMMARY - SEAFARMS WEST CUP 194(A) & (B) RePional Water Qualitv Control Board Proposed Agua Hedionda Coliform Study submitted to City for review. - Considering making Carlsbad, along with Encina WPCF and Oceanside, responsible for study at estimated cost of $500,000 - $700,000. Study apparently required due to high concentrations of coliform found in Seafarms shellfish prior to flushing process. 1. Study to identify cause of pollution of Seafarm West products. 2. Determine necessary mitigation of potential health hazards associated with Seafarms. Given potential health hazards and public expense required for the study, removal of Seafarms would eliminate the need to develop studies to id cost of shellfish pollutants/contamination. Engineering maintains that public funds should not be used to support private business. Apparently State Water Quality Board, through Order 90-42, is adequately addressing non point source pollution. Engineering wants to evaluate the cost to the public of proposed coliform studies versus the cost to Seafarms to decontaminate the shellfish.